program launch for new cdbg-dr grantees · 2019 cdbg -dr problem solving clinic • appropriations...
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2019 CDBG-DR Problem Solving Clinic 1
2019 CDBG-DR Problem Solving ClinicKansas City – Overland Park | J u l y 3 0 – A u g u s t 1 , 2 0 1 9
Program Launch for New CDBG-DR Grantees
2019 CDBG-DR Problem Solving Clinic
• Session Objectives Identify the steps that new grantees must take prior to signing a grant
agreement and launching their program• Speakers Steve Higginbotham, ICF Jen Carpenter, HUD
Welcome and Speakers
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2019 CDBG-DR Problem Solving Clinic
• Public Laws and Federal Register Notices• The Action Plan• HUD Certifications• Operational First Steps
Agenda
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2019 CDBG-DR Problem Solving Clinic
Public Laws and Federal Register Notices
2019 CDBG-DR Problem Solving Clinic
• Public Law describes which Federal departments and agencies receive appropriations for the designated disaster(s)
• Federal Register Notice – read and study Allocates funding to grantees May restrict where funds can be spent (MID URN areas) Describes waivers and alternative requirements governing the allocation Lays out the process Grantees must follow prior to executing their grants Describes ongoing requirements for financial management and reporting
Public Laws and Federal Register Notices
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2019 CDBG-DR Problem Solving Clinic
Life Cycle of a CDBG-DR Grant
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2019 CDBG-DR Problem Solving Clinic
The Action Plan
2019 CDBG-DR Problem Solving Clinic
• Prepared by the Grantee• Action Plan Elements Assessment of damage:
‒ Housing‒ Infrastructure‒ Economic revitalization
Analysis of unmet needs Plan to allocate available funding to a combination of housing, economic
development, infrastructure, and services programs, based on needs assessment.
Developing the Action Plan
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2019 CDBG-DR Problem Solving Clinic
• Action Plan Elements (cont.) Other items required by Federal Register Notice (e.g. cross- cutting federal
requirements, non-displacement, not suitable for rehabilitation)
• Must make Action Plan available for public comment Include comments and Grantee response in Action Plan submission
• Include any new waivers with (or before) Action Plan Submission• Submitted to HUD for approval within stated timeframe
Developing the Action Plan (cont.)
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2019 CDBG-DR Problem Solving Clinic
HUD Certifications
2019 CDBG-DR Problem Solving Clinic
• Appropriations Act requirement• Requirement for all new grantees• Must be updated by older grantees if policies have changed since
HUD approval or last award was 2011 storms or earlier• Grantee should plan to submit in advance of Action Plan submission• Must be approved by Secretary in advance of grant signing• May require review by HUD Chief Financial Officer and Office of
Inspector General
HUD Certifications
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2019 CDBG-DR Problem Solving Clinic
• Financial Standards Financial Controls Internal Controls Payment and Financial Reporting Policies & Procedures Policies & Procedures dealing with Improper Payments Program Income Revision of Budget and Program Plans Period of Performance Record Retention and Access Audit Requirements
HUD Certification Requirements
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2019 CDBG-DR Problem Solving Clinic
• Procurement Policies and Procedures• Procedures for the Prevention of Duplication of Benefits• Procedures to Determine Timely Expenditures• Procedures to Maintain a Comprehensive Website• Procedures to Detect and Prevent Fraud, Waste and Abuse of Funds
HUD Certifications
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2019 CDBG-DR Problem Solving Clinic
Disaster Recovery Grant Reporting System (DRGR)
2019 CDBG-DR Problem Solving Clinic
• DRGR User Accounts Work with CPD Rep to create DRGR Grantee Administrator user accounts Grantee Administrators must request all other user accounts in DRGR
• After Action Plan approval Execute grant agreement and establish LOCCS banking Complete and submit DRGR Action Plan for approval
‒ Must be substantially similar to published action plan‒ At minimum, DRGR Project budgets must sum to grant award‒ Drawdowns occur at the DRGR activity level
• Submit first drawdown Confirm receipt of funds from LOCCS into local account
Initial DRGR steps
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2019 CDBG-DR Problem Solving Clinic
• Continue to edit DRGR Action Plan, as necessary Must always align with published action plan CPD Rep must approve all edits to the DRGR action plan
‒ Cannot draw funds for newly created activities until CPD Rep approval• Quarterly Performance Reports First QPR due 30 days after the first full quarter after the Grant Agreement is
executed‒ Ex: if the grant agreement is executed on February 15, the first QPR is due on July 30‒ Submit every quarter thereafter until grant close-out
• DRGR trainings and resources https://www.hudexchange.info/programs/drgr/
Ongoing DRGR steps
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2019 CDBG-DR Problem Solving Clinic
Operational First Steps
2019 CDBG-DR Problem Solving Clinic
• Prepare to Expand Operations!• Grants Management Assess your business processes, IT systems, staff capabilities, and institutional
infrastructure Determine needs for new equipment, expanded office/facilities space Evaluate current systems and processes to determine areas for improvement,
augmentation – identify additional assistance you may need to accomplish
Operational First Steps
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2019 CDBG-DR Problem Solving Clinic
• Program Management Successful program implementation requires:
‒ Increasing staff size‒ Cultivating new partnerships with other agencies, subrecipients and contractors
Determine the implementation model(s) you will use:‒ Direct – Grantee implements‒ Partner – Grantee partners with other agencies or contractors‒ Distribution – Grantee funds Units of General Local Government‒ Models can be combined‒ Decision based on tradition, capacity, complexity‒ Detailed policies and procedures required for any model
Operational First Steps (cont.)
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2019 CDBG-DR Problem Solving Clinic
Prior to deciding whether to procure an outside contractor, keep the following things in mind:
• All costs need to comply with general cost principles: Allowable (2 CFR 200.403) Reasonable (2 CFR 200.404) Allocable (2 CFR 200.205)
• Additional considerations for contracted professional services: Professional Service Costs (2 CFR 200.459) Determining allowability of costs:
‒ Are the services needed?‒ Could the grantee have done the services in-house?‒ Is it cost effective to contract vs. in-house with existing or additional staff?‒ Is the contractor qualified?‒ Are the costs appropriate for the services being provided?‒ Is the contract adequate?
Operational First Steps (cont.)
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2019 CDBG-DR Problem Solving Clinic
• Procurement and Contract Management Evaluate current policy for consistency with 2 CFR Part 200.317 – 200.326 Develop or update policy & procedures for subrecipients
• Compliance and Monitoring Develop policies & procedures Conduct risk assessments of subrecipients
• Execute data sharing agreements and start collecting data• Track time and costs spent on CDBG-DR activities pre-award (e.g.
Action Plan development) as these are reimbursable costs• Understand the CDBG-DR program life cycle
Operational First Steps (cont.)
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2019 CDBG-DR Problem Solving Clinic
https://www.hudexchange.info/programs/cdbg-dr/toolkits/program-launch/
https://files.hudexchange.info/resources/documents/Disaster_Recovery_Disaster_Impact_Needs_Assessment_Kit.pdf
https://www.hudexchange.info/programs/cdbg-dr/
https://www.hudexchange.info/programs/cdbg-dr/cdbg-dr-laws-regulations-and-federal-register-notices/
Resources and Tools:
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Questions?
Steve Higginbotham ([email protected])Jen Carpenter ([email protected])